Two Non-US Banks Agree to Pay Penalties Totaling $160 Million for Violations of US Sanctions Laws Resulting from Omnibus Account and Related Services

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial intermediaries, to implement measures to ensure compliance with those laws. These actions highlight the significant compliance risks faced by non-U.S. financial institutions that conduct business through the U.S. financial system while maintaining accounts on behalf of entities subject to U.S. sanctions. In addition, the cases represent the latest in a series of regulatory actions highlighting the anti-money laundering (“AML”) and sanctions compliance risks presented when U.S. financial institutions maintain omnibus accounts in the United States for non-U.S. financial institutions.